Wells and Wade Fruit Company - Executive Summary |
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A. Accidental Release Prevention and Emergency Response Wells and Wade Fruit Co. (hereafter referred to as Wells and Wade) accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. It is the policy of Wells and Wade to adhere to all applicable federal and state safety and environmental regulations. Wells and Wade's emergency response policy involves the preparation of response plans and training of employees in evacuation and the handling of ammonia releases. Wells and Wade's emergency response policy involves the preparation of response plans and training of employees. Wells and Wade has trained its refrigeration personnel in hazardous materials response (24 hours). This training includes emphasis on anhydrous ammonia, in addition to other requirements set forth in 29 CFR 1910.120(q) and WAC 296-62, Part P (HAZWOPER). At Wells and Wade anhydrous ammonia is used on-site. Ammonia is listed on the Extremely Hazardous Substance (EHS) list. B. Facility and Regulated Substance Handled Wells and Wade is a fruit processing and cold storage facility, located at 201 S. Union, East Wenatchee, WA. The facility is located in Douglas County. The regulated substance used at Wells and Wade is anhydrous ammonia (CAS# 7664-41-7). The use of anhydrous ammonia is as a refrigerant. There are 16,250 pounds of anhydrous ammonia in the refrigeration system and is the only system subject to the RMP program. Wells and Wade has established policies, procedures and training to reduce the risk of an accidental hazardous substance release for the safety of its employees and surrounding areas. C. Worst-Case and Alternative Scenarios The off-site consequence analysis considers two ammonia release scenarios identified as "worst case" and "alternative" scenarios. The worst case scenario is defined by the Environmental Protection Agency (EPA), which states that "the owner or operator shall assume that the ma ximum quantity in the largest vessel is released ". The alternative scenario is defined as "more likely to occur than the worst case scenario". Worst-Case Scenario. - Failure of the largest vessel would release 7300 pounds of anhydrous ammonia, however in order to obtain a true worst-case, the entire system inventory (rounded up) of 17,000 pounds was modeled. The release would occur inside the compressor room, which is not in direct contact with the outside. Although for modeling purposes, no mitigation was taken into account. Although building mitigation was not used, the building containment would be a substantial mitigation factor. Modeling was done by use of RMP-COMP. The distance to the EPA end-point is off-site Alternative Release Scenario - For the alternative scenario, it was assumed that the system would loose its entire inventory over a 30-minute period, without any mitigation. Modeling was done by use of RMP-COMP. The distance to the EPA end-point is off-site Both the "worst-case" and "alternative" scenarios are unlikely because Wells and Wade has employed the following control and mitigating measures. 7 Industry standards and quality controls were followed in the design of this equipment and its manufacture. 7 The facility utilized a preventive maintenance program to maintain the ongoing integrity of the vessel. 7 The facility has a training program that insures only qualified personnel operate the system. 7 The facility requires that all PSM elements as well as company maintenance policies are followed. 7 The facility has trained emergency response personnel and procedures on site to respond quickly to isolate and potential releases. 7 Only trained and authorized personnel have access to the system. 7 The system was designed using standard practices and is maintained by rigid company standards. 7 The piping is routed to avoid impact from traffic sources. A more realistic scenario would be that of a pressure relief valve lifting, discharging ammonia vapor from vents on top of the building and the EPA end-point just extends past the boundaries of the plant. Wells and Wade has coordinated notification procedures with the Pangborn Airport Fire Chief. D. General Accidental Release Prevention Program Wells and Wade's accidental release prevention program is based on the following key elements: 7 High level of training of personnel 7 Preventative maintenance program 7 Written safety procedures and safety equipment 7 Use of accurate and effective written operating procedures Wells and Wade also complies with: 7 OSHA's and Washington State's process safety management rule. 7 Applicable Washington State's safety regulations (WAC's 296-24 and 296-62). 7 IIAR (International Institute of Ammonia Refrigeration) standards for good work practices. 7 Applicable local fire code for handling of hazardous materials. The ammonia refrigeration system was installed to applicable codes and good practices at the time of installation. Pipin g is elevated to prevent accidental damage to the system from moving vehicles. Engine room doors are tight fitting and open outwards. Other safety devices Wells and Wade utilizes include: 7 Computerized controls, which can be operated remotely 7 Suction trap hi-level float 7 High discharge pressure shut down 7 Low suction pressure shut down 7 High discharge temperature shut down 7 Oil pressure failure shut down 7 High amperes shut down 7 Automatic timer to prevent short cycling 7 Oil filters plugged shut down 7 250 psi relief valves on high pressure side, to prevent overpressure situations 7 150 psi relief valves on low pressure side, to prevent overpressure situations 7 Emergency ventilation Operating Procedures have been prepared by Wells and Wade to be used by employees performing operational functions. The o perating procedures are kept in the refrigeration manager's office. These procedures include: 7 Pre-start up procedures 7 Routine operations 7 Maintenance 7 Response to minor releases 7 Emergency action plan E. Five-Year Accident History Wells and Wade has not had any accidents involving ammonia in the last five years. F. Emergency Response Program In addition to the operating procedures, Wells and Wade has established Emergency Response Guidelines for releases involving ammonia. These procedures are part of the ongoing training. Our facility is a member of and participates with the Douglas County LEPC. Refrigeration personnel have received appropriate technician level training from the Ammonia Safety Training Institute (ASTI). G. Planned Safety Improvements Currently, Wells and Wade plans to install separate audible alarms for both fire and an ammonia release. These will provide for distinctive warning to provide better warning for our employees. Wells and Wade will continue to ensure that its employees assigned to work on the process receive current training. |